The Swedish National Contact Point (NCP) for the OECD Guidelines for Multinational Enterprises has concluded a complaint brought by Justice for Iran (JFI) and Justice Beyond Borders (JBB) against Swedish surveillance technology company Axis Communications, resulting in a constructive dialogue and a joint commitment to continue discussions on technology and human rights.
The complaint concerned the sale of Axis Communications’ video surveillance products, particularly surveillance cameras, to companies operating in the Islamic Republic of Iran. JFI and JBB argued that, given the well-documented use of surveillance technologies by Iranian authorities to identify, monitor and prosecute protesters, journalists, women’s rights defenders and other dissidents, companies supplying such technologies have a responsibility to conduct robust human rights due diligence before entering or maintaining commercial relationships in Iran.
The organisations emphasised that crimes against humanity have been committed by the Iranian authorities during successive waves of protest repression, including the November 2019 Aban protests and the nationwide crackdown following the death of Mahsa Amini in 2022. Referring to the findings of the Aban Tribunal and the reports of the United Nations Independent International Fact-Finding Mission on Iran, JFI and JBB argued that the role of surveillance cameras in facilitating arbitrary arrests, prosecutions and other serious human rights violations has been extensively documented.
Unlike several recent OECD complaints involving technology exports to Iran, the Swedish NCP facilitated direct discussions between the parties. During the process, Justice for Iran, Justice Beyond Borders and Axis Communications explored the human rights challenges associated with surveillance technologies and the responsibilities of companies operating in high-risk environments.
Following the dialogue, the parties submitted a joint statement to the Swedish NCP, affirming their shared commitment to continued engagement.
“In the spirit of cooperation and given the potentials and challenges that different types of technology pose, Justice for Iran/Justice Beyond Borders and Axis Communications agree to continue to hold dialogues on issues relating to technology and human rights.”
The outcome represents a noteworthy example of the OECD National Contact Point mechanism functioning as a platform for constructive engagement rather than adversarial proceedings. While the process did not result in findings of non-compliance, it created an opportunity for civil society organisations and a multinational technology company to engage directly on the human rights implications of surveillance technology exports.
For the business and human rights community, the case reflects the increasing scrutiny facing manufacturers of surveillance technologies whose products may be deployed in authoritarian settings. It also reinforces the expectation under the OECD Guidelines that companies should assess and address the human rights risks associated not only with their own operations but also with their distribution networks and commercial relationships.
As governments around the world expand their use of digital surveillance, this case demonstrates how non-judicial grievance mechanisms can facilitate dialogue, encourage responsible business conduct and strengthen corporate awareness of human rights risks. For NGOs, lawyers and corporate accountability advocates, it offers an example of how engagement through OECD National Contact Points can contribute to meaningful discussions on the governance of technologies that increasingly shape the protection—or violation—of fundamental rights.



